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eter and larger while 3" and smaller waste lines are covered by specifications for ABS and high density polyethylene.

EXHIBIT B

UNIROYAL, LTD., Bromsgrove, Worcestershire, August 24, 1970 UNIROYAL INTERNATIONAL, Division of Uniroyal Inc., Uniroyal Chemical, Navgatuck, Conn.

For the attention of Mr. Rom Rhome.

DEAR ROM: This is a letter to confirm certain Andings on DWV pipe in up to 3" diameter.

A new UK. draft specification for Plastics Waste Systems, released on limited circulation in the last six weeks and which is to be regarded as confidential information, relates to Domestic Waste Systems manufactured in specific plastic materials. The only materials covered are ABS, Chlorinated PVC, Polypropylene Copolymer and HD. P/E. PVC is not included. Only three sizes of pipe and fittings are covered, namely 14", 1" and 2"

It can therefore be stated that in the UK. at the present time no specification exists in the up to 3" size which covers the use of PVC for use in domestic waste systems. We believe that the use of PVC is precluded because of the high water temperatures experienced in the UK. by the use of such archalc but nevertheless efficient articles as back boilers. These are installed into UK. homes at the rate of 120,000 per annum even now. Water discharge can be intermittent at very near 100 C. and PVC is unsuitable although I have no documentation to support this.

There are no plans as far as is known to introduce PVC into this specification. Kind regards, see you in the near future. Yours sincerely,

R. M. BROUGHTON, Kralastic Technical Service.

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The most common pipe sizes with outside diameters in millimeters and their British nominal equivalents are the following:

32 mm. 14.
40 mm. 1".
50 mm. 2".

75 mm. 3" (2.95" OD.).
90 mm. 3" (3.54" O.D.).
110 mm. 4".
160 mm. 6".
200 mm. 8".

In the above table of sizes, 90 mm. approximates the 3.5" outside diameter used in the United States for both pressure and drainage. On the Continent 90 mm. has been the standard 3 pipe size for pressure because of the heavier wall rated for 10 atmospheres, while 75 mm. was used for drainage. This diameter was originally produced with a wall thickness of only 1.8 mm. It is now being increased to 3.2 mm. With the heavier wall of 3.2 mm., the bore of 75 mm. will be constricted to 2.70 With more conservative design, 90 mm. would be the more appropriate outside diameter which is equivalent to the U.S. 3" nominal pipe.

4. TEMPERATURE Everyone is familiar with the fact that 0°C is equivalent to the freezing temperature of water at 32 F, and that 100° C is the bolling point of water at 212°F. One degree C is, of course, equal to 9/5 of one degree F. However, some other benchmarks in the temperature scale are of interest.

60° C is the test temperature for determining long-term hydrostatic stress test for PVC. It is also the maximum operating temperature recommended for PVC pressure pipe in high temperature systems. 60° C equals 140* F.

70 C or 158 F is the maximum temperature of effluent recommended for PVC drainage systems. ABS drainage pipe, however, is considered suitable for wastes up to 90° C or 194 F. under the Dutch KOMO specification for ABS.

Ambient temperature is considered 20° C or 68 F. in Europe.

5. PRESSURE RATING

In Europe PVC 100 is the standard design stress for unplasticized PVC for pressure piping. The stress is determined by long term burst tests with water at 20° C, extrapolated on a log-log scale to fifty years.

The design stress of 100 kg./cm.2 is equivalent to approximately 1400 psi. for a service life of 50 years. In the United States the same PVC material would be given a design stress of 2000 psi. for 100,000 hours or approximately 12 years.

Classes of PVC pipe are rated in multiples of one atmosphere (14.7 psi.). The most common pressure rating is 10 atmospheres or 147

pat. Georg Fischer, for example, manufac tures a single line of PVC pressure fittings rated at 10 atmospheres working pressure.

APPENDIX B-AGENCIES, COMPANIES, AND INDIVIDUALS INTERVIEWED

1. UNITED KINGDOM

(a) Chemidus Plastics, Ltd., Brunswick Road, Cobbs Wood, Ashford, Kent, England. R. Broome, Works Director: J. B. Steel, R&D Unit; David Street, R&D Unit.

(b) Hunter Group of Companies, Nathan Way. Woolwich Industrial Estate, London, S.E. 18, England. R. H. Edmondson, Werks Director; R. J. Heddon.

(c) Durapipe & Fittings, Ltd., Bentinck Road, West Drayton, Middx, England. Eric E. Denyer, Executive Director.

(d) Allied Ironfounders, Ltd., R. W. S. DIvision, Ketley, Wellington, Shropshire, England. H. H. M. Milnes, R. W. 8. Director.

(e) Lambert Brothers (Walsall) Ltd., Walstead Road West, Staffordshire, England. D. C. Barrett, Engineering Manager.

(f) Fire Research Station, Ministry of Technology and Fire Offices Committee, Boreham Wood, Hertfordshire, England. H. L Malhoutra.

(g) Building Research Station, Ministry of Technology, Garston, Watford, Hertfordshire, England. M. Lillywhite.

(h) Uniroyal, Ltd., Chemical Division, P. O. Box 12, Bromsgrove, Worcestershire, England. G. A. Sullivan, Managing Director; J. M. Kelly, Technical Director; Brian Sitch, Sales Manager: John W. Muncle, Export Manager; Robert Broughton, Technical Serv. ice Manager.

2. NETHERLANDS

(a) Polva-Nederland N.V., Postbus 14, Enk. huizen, Elevolaan 5, Holland. Dr. Paul Benjamin.

(b) Dijka N.V., Productieweg 6: Steenwijk, Holland. Dik van Dijk, Sr.; Dik van Dijk, Jr.; Mr. Müller.

(c) Wavin, Zwolle, postbus 173, Händellaan 251, Holland, Dr. W. J. de Putter; W. H. Ros.

(d) TNO-Plastics & Rubber Research, Schoenmaker Neuf 97, Delft, Holland. Dr. T. A. der Kinderen.

(e)

KIWA-Institution for Testing of Water Works Materials, Ltd., 273 Sir Winston Churchill-laan, P. O. B. 4570, Rijswijk (Z.H.), Holland. Ir. J. H. F. Kalkman; 8. Birkenfeld.

(f) Marbon Europe N.V., P. O. Box 8123, Kabelweg 55, Sloterdijk, Amsterdam, Holland. Alex L. Leigh, Managing Director; H. D. Feeney, Sales Director; P. A. M. Ellis, Applications Development Engineer.

(g) Transmare N.V., Handelmaatschappij. P. O. Box 1120, Rotterdam 1, Holland. Albert Heida.

3. SWITZERLAND AND GERMANY (a) Georg Fischer AktiengesellschaftPlastics Division, Schaffhausen, Switzerland. Christian Moser, Managing Director; Dr. Rudolf Merz, Fritz Reich.

(b) Gebruder Anger, Kunststoffwerk, 80 Einsteinstrasse 104, 8 München, Germany. Obering. Karl Jirka; Axel Below.

4. FRANCE

(a) Plastimer, 98 Boulevard Victor Hugo, 92 Clichy, Paris, France. Bertrand Gruson; Philippe Martin.

(b) Centre Scientifique et Technique du Batiment, (Translation: Scientific and Tech nical Center for Building). C.S.TR. 4, Ave. du Recteur-Poincaré, Paris XVI, France.

89TH ANNUAL CONVENTION, NATIONAL ASSOCIATION OF PLUMBING-HEATING-COOLING CONTRACTORS, RESOLUTION NO. 5

Sponsor: New York State Association of Plumbing-Heating-Cooling Contractors, Inc.

Whereas fidelity to democratic principle and procedures is one of the most highly cherished traditions of the National Association of Plumbing-HeatingCooling Contractors; and

Whereas our national association has undertaken to publish a model plumbing code known as the National Standard Plumbing Code; and

Whereas other sponsors of model plumbing codes have in recent years been criticized sharply for lack of due process and democratic procedure as, for example, when Building Officials and Code Administrators International adopted its Basic Plumbing Code without submitting same to a vote of its membership; and

Whereas all other sponsors of model plumbing codes, including even BOCA, allow no amendment or revision of their respective codes except by vote of the membership at an annual conference; and

Whereas it behooves the NAPHCC to adopt the same democratic procedures in amending the National Standard Plumbing Code, in order to avoid criticism from public officials and inquiry by various legislative bodies, and also to enhance the general acceptability of the code: Now, therefore, be it

Resolved, That there exists in the NAPHCC the inherent right to amend the National Standard Plumbing Code by membership initiative that any affiliated state or local association may propose amendments for consideration and vote at an annual convention of the NAPHCC; and that any action taken by the membership at an annual convention to amend said code may not thereafter be rescinded, amended, or otherwise disturbed or affected by the Board of Directors or any other subordinate body or officer of the NAPHCC, but only by the membership voting at a subsequent annual convention; provided, however, that it is allowable for the Board of Directors or other competent committee or task force to submit recommended changes for membership vote at an annual convention. Resolutions Committee do not concur.

[From Air Conditioning, Heating & Refrigeration News, June 26, 1972]

MOVE AGAINST FOREIGN BOILERS RESOLVED BY CONSENT JUDGMENT

The Department of Justice filed a proposed consent judgment which would terminate a civil antitrust suit against the American Society of Mechanical Engineers and the National Board of Boiler and Pressure Vessel Inspectors.

The civil suit was filed July 22, 1970, charging the defendants with violating Sections 1 and 2 of the Sherman Act.

Attorney General Richard G. Kleindienst said the judgment, which may be entered after 60 days upon approval by the court, was filed in U.S. District Court in New York City, where the ASME maintains its national office.

The suit charged that the defendants combined in unreasonable restraint of trade to exclude foreign-made boilers and pressure vessels from sale within the United States.

According to the suit, the defendants arbitrarily refused to permit use of the ASME or National Board stamps, which attest that the products meet technical safety standards, by foreign manufacturers of boilers and pressure vessels, and referred to register such boilers and pressure vessels with the National Board. The complaint further alleged that registration and the application of such stamps facilitates the approval of boilers and pressure vessels for installation in most states under state and local laws and regulations.

Acting Assistant Attorney General Walker B. Comegys, in charge of the Antitrust Division, said the proposed judgment requires that the two associations make their respective stamps available on a fair, reasonable, and nondiscriminatory basis to foreign manufacturers who meet the safety and technical standards applicable to American producers.

The judgment also requires the National Board to register boilers and pressure vessels which meet the appropriate safety standards without regard to whether they are made by a domestic or a foreign manufacturer, he said.

Comments to the Department of Justice and the court regarding the proposed judgmment are invited from the members of the public during the 30-day waiting period prior to the judgment's becoming final. The proposed judgment was filed on June 13.

[From the Congressional Record, Dec. 10, 1970]

APPROVAL OF BUILDING MATERIALS IGNORES CONSUMER INTERESTS

Mr. KLUCZYNSKI. Mr. Speaker, during the course of the 91st Congress, the Subcommittee on Small Business Problems in Smaller Towns and Urban Areas, of which I am chairman, has investigated the effects on small business and the general public of certain policies of the Department of Housing and Urban Development.

The policies to which I refer relate to the approval of certain building materials and methods, and to HUD's requirement that every local government having a workable program for community improvement approve model codes which contain these materials.

A well-known organization with a deserved reputation for representing consumer interests, the Consumer Federation of America, has responded to certain questions I raised in a letter of September 29, 1970. The replies were contained in a letter of November 30, 1970, signed by Mrs. Erma Angevine, executive director of Consumer Federation of America.

Mrs. Angevine makes the point that HUD should adopt performance standards for building materials and then proceed to establish by independent inquiry and independent testing which materials meet these standards.

It is my understanding that this is precisely what HUD is not doing at the present time.

Mr. Speaker, members of the consuming public have a far greater stake in their homes than in any other goods or services on the market. This is obvious in the case of the homeowner. It is also true for those who rent their homes, since the monthly rent payment normally exceeds every other item of domestic expenditure in the family budget.

For the rest, Mrs. Angevine's letter speaks for itself and in view of the importance and timeliness of the subject matter, I am placing it in the RECORD:

"Hon. JOHN C. KLUCZYNSKI,

"CONSUMER FEDERATION OF AMERICA,

"WASHINGTON, D.C.,
"November 30, 1970.

Chairman, Subcommittee No. 3, Rayburn House Office Building, Washington, D.C. "DEAR CHAIRMAN KLUCZYNSKI: I wish to commend you and your colleagues on the very valuable work you have undertaken to explore federal, state, and municipal construction requirements and their effect on U.S. consumers of housing. I wish also to comment, as you requested, on four specific points raised in your September 29 letter, as follows:

"1. The acceptance of new materials, without testing either by a federal agency or an independent laboratory. Apparently, Federal Housing Administration is willing to accept materials purely on the basis of representations of the producer of material.

"CFA comment: Obviously, the public interest requires that an independen party test new building products and materials. Whether a federal agency or ai independent laboratory should do so must depend on their capabilities. FHA's acceptance of any material 'purely on the basis of representations of the producer' is not satisfactory from the standpoint of the consumer or the public interest.

"2. Although sometimes paying lip service to the concept of performance standards, FHA continues to opt for products of specific standards. In other words, rather than defining the minimum performance of a wall, a pipe, or similar component, which would allow any material complying with these performance standards to be used, FHA follows the somewhat dubious policy of listing those products which are acceptable.

"CFA comment: We vigorously support performance standards. Such standards tell the consumer how the product will perform under various conditions and thus enable him to choose among many similar products that may vary considerably in price.

"For example, our goal is not to describe a wall in terms of the materials used in its construction but to describe it in terms of its rigidity, its strength, and its effectiveness as a barrier to cold, heat, moisture, noise, and so forth. An acceptable standard, from the consumer's standpoint, would establish minimum requirements for each of these characteristics. A federal, state, or local agency that approves materials without first, establishing performance standards and, second, determining if the material meets these standards is not acting in the public interest.

3. The above two paragraphs must be viewed against the background of an increasingly vigorous insistence by the Department of Housing & Urban Development that material approved by them must be accepted by local communities. "CFA comment: We understand the Department's desire to encourage use of newly-developed building materials when these function as well or better and cost less than more traditional materials and to open up such state and municipal building codes as may bar use of these newer material. However, the solution is not for the Department to prescribe new materials untested by independent parties for their performance characteristics. The solution is for the Department to adopt performance standards and establish by independent inquiry which materials, new or traditional, meet these standards.

"4. Even though upon occasion FHA requires that a guarantee or warranty be given the consumer if certain products, such as plastic pipe, are used, this does not appear to result in increased consumer protection. In fact, I am concerned that it may detract from the consumer's total position. The warranty gives the appearance of protection without any of the undergirding benefits usually associated with warranties. You will find enclosed a copy of such a warranty. I am sure you can decide for yourself whether it actually protects the consumer. Further, the Subcommittee is the recipient of numerous complaints that all too often the warranty is not actually delivered to the home buyer. I am enclosing for your information the transcript of hearings recently held in Chicago on this subject together with the printed hearings and report of proceedings held last spring on related matters.

"CFA comment: A manufacturer must, of course, deliver his warranty to his customer if the warranty is to have any value. If the person who buys a house in which plastic pipe is installed has no knowledge of the Acrylonitrile-ButadieneStyrene Institute warranty, it is of course useless to him.

"I understand, under the standard ABS Institute warranty, that a plastic pipe manufacturer promises to repair his product in event of failure and that the Institute's decision regarding the necessity of such repairs shall be final. This raises the question whether the Institute can deal at arm's length with its manufacturer members so as to render an independent judgment. Unfortunately for consumers, the history of industries' policing members of those industries is a dreary story.

"I appreciate your work, Mr. Chairman, and I hope you will continue to insist that federal, state, or local approval of construction materials be soundly based on independent judgment of the ability of those materials to perform their function. In this direction lies the consumer's interest."

"Sincerely,

"ERMA ANGEVINE, Executive Director."

Senator TOWER. Our next witnesses are a panel, I believe. Mr. David C. Kornreich, Mr. Charles B. Mahin and Mr. William B. Marx. What we will do is let you three proceed in your own way and we will put the questions to all three of you.

STATEMENT OF CHARLES B. MAHIN, REPRESENTING NATIONAL WOODWORK MANUFACTURERS ASSOCIATION, INC.

Mr. MAHIN. Mr. Chairman, members of the committee, our arrangement is, I will lead off and Mr. Marx and Mr. Kornreich will follow. If the chairman please, I have filed a statement which I would prefer merely to summarize to save time. I request that my full statement be included in the record (See p. 137).

I was interested in Congressman Dingell's comments because it seemed to me that he had the impression that the purpose of this bill was to create some kind of a Federal standard. That is not the focus of the bill as we see it at all.

The focus of this bill is to eliminate boycotts and trade restraints which prevent technological improvement in housing, and the "standards" feature comes in merely as a presumption factor in litigation.

If the defendants claim that there is health and welfare involved, then we get a presumption if we happen to conform with some approved standard. That is an ancillary sort of thing and it is not the real focus of the bill, as you have pointed out to the Congressman. I am a member of the Chicago law firm of Price, Cushman, Keck & Mahin, and I represent the National Woodwork Manufacturers Association.

In 37 years of my practice a good amount of time has been spent in labor law matters in construction and building material industries. I personally have been involved in major boycott litigation: the Joliet Contractors case, the Sand Door case, General Millwork and National Woodwork, which is the last one.

The National Association of Woodwork Manufacturers that I represent has 101 members and they make most of the doors and windows and millwork which is used in residential construction in the country.

Our industry is vitally concerned with the thing that your committee is concerned with, and that is the skyrocketing costs of home construction, and one major feature that contributes to these high costs is the product boycotts and other restrictive practices that are pursued by the building trade unions.

They stifle technological advances, and the industry people here today are here to give you some of the illustrations that we have personally experienced and personally know about in that particular

area.

Why is this legislation necessary? Twenty-five years ago when we were down here and the Taft-Hartley Act was passed, no one would have believed that we would be down here now asking for protection against product boycotts. Everybody thought that 8(b) (4) (A) solved the problem. But the Supreme Court in its majesty in the Sand Door case opened wide loopholes which permitted product boycotts wherever they were accomplished by coercion of employers or by contract. The public reaction to this decision was fast.

The next year in the Landrum-Griffin bill, you remember we were down here again, and 8(b) (4) (B) was enacted and everybody thought the product boycott problem was solved.

That was only 13 years ago.

Now, the Supreme Court has intervened again and in a 5-to-4 decision, they came out with this unbelievable result that product boycotts are legal under the act if a union can contend that it was applying the boycott in order to preserve work for its people. Somebody has to do the work-the fellow on the job or the fellow in the factory. And if the job union says the prefabricated product "is taking work away from my people," under this work preservation theory that boycott is not lawful.

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